2017年-FCA英国金融行为监管局_smarter_communications_ineffective_requirements_handbook_4页_140kb

Summary of Regulator Assessment: Qualifying Regulatory Provisions

Title of Proposal

Smarter Communications: Removing ineffective disclosure requirements in our Handbook

Lead Regulator

Financial Conduct Authority (FCA)

Date of Assessment

19 July 2016

Commencement Date

February 2017

Origin

Domestic

Scope of Impact

The proposal affects all sectors of the UK financial services industry, with specific impacts on the following areas:

• Insurance companies operating with profits business, their customers, potential customers, and firms providing advice on this business (CFPPFM)
• Authorised fund managers of UCITS schemes and non-UCITS retail schemes, along with services providers (Short Report)
• Home finance and investment firms and general insurance firms (IDD & CIDD)
• All firms offering advice to retail clients or arranging transactions for them in relation to packaged products (SCDD)

Core Content of the Proposal

The FCA initiated the Smarter Consumer Communications initiative to simplify and improve the clarity of financial communications by removing ineffective disclosure requirements. The key regulatory provisions being removed are:

1. Consumer-Friendly Principles and Practices of Financial Management (CFPPFM)
2. Short Report for UCITS and non-UCITS retail schemes
3. IDD, CIDD, and SCDD templates

These changes aim to reduce unnecessary administrative burdens on firms while ensuring that consumers still receive clear and relevant information.

Cost Benefit Analysis Summary

CFPPFM Removal

• Business Impact: Removal of an annual obligation to produce the CFPPFM.
• Estimated Annual Savings: £520,000 (based on 52 firms, with an average cost of £10,000 per firm).
• Actual Savings: Estimated at £500,000 after considering two firms that may still produce the document.
• One-off Costs: £10,000 per firm (assumed 50% of savings will be used for alternative communication methods).
• Total One-off Costs: £500,000
• Annual Savings: £300,000 (rounded)
• Assumed Duration: 10 years

Short Report Removal

• Business Impact: Removal of the requirement to produce annual half-yearly short reports.
• Estimated Annual Savings: £15.3m (based on 6.7m to 8.1m reports produced per year, with an average cost of £1.79 to £2.27 per report).
• Assumed Duration: 10 years

IDD & CIDD Templates Removal

• Business Impact: Removal of mandatory templates and guidance on using them.
• Estimated Impact: Neutral (no significant cost or savings expected).
• Reasoning: Firms will gain more flexibility in presenting information, which could lead to minimal cost savings or additional costs in the short term. The FCA delayed the implementation date to allow firms to use existing stock, minimizing one-off impacts.

Key Information and Outcomes

• Total Estimated Annual Savings from the removal of CFPPFM and Short Reports: £15.3m + £300,000 = £15.6m
• One-off Costs associated with the CFPPFM removal: £500,000
• BIT Score: -69.5 (as per the table provided)
• Net Present Value (NPV) of the policy: 133.8
• Net Cost to Business (EANDCB): -13.9
• Duration of Policy: 4 years (based on the table)

The FCA concluded that the removal of these disclosure requirements would lead to significant cost savings for firms while promoting more effective and consumer-friendly communication practices.